SW Associates’ Privacy and Use of Personal Data Policy, applicable from 25th May 2018
For further information on the protection of personal data: https://www.cnil.fr/.
1. Data Processing manager (within the meaning of the 78-17 law known as the “CNIL” law)
Legal reminder: The manager is the person who determines the means and purposes of the processing. The subcontractor is a person processing personal data on behalf of the manager. They act under the authority of the manager and follow their instructions. SW Associates is a subcontractor: we act on the specific instructions of each insurer/broker.
Personal information is information that relates to an identified or identifiable individual, such as the name, an email address, a telephone number, a postal address or the computer IP address.
Identification of collected data, purpose and exploitation of processed data
In order to fulfil its contractual obligations, SW Associates collects the data necessary to implement its services. The use of your data is governed by the contract that binds us to the party for whom we are acting.
To better understand the data processing done by SW Associates, we invite you to read the following information:
|Purpose of processing||Type of data|
|Management of Claims and Surveys||Title, Surname, Given Name (s), Address, Phone Numbers, E-mail Address|
Relevant data for the compensation of claims: postal or bank account details,
Location and identification of insured property (e.g., address of the property), condition report for damaged artworks.Policy details and claims numbers, details of coverage and risk, as well as cause of loss, photos and videos, loss history, underwriting forms, security measures, financial information.
|a)||Sources of personal data|
|Initially they are communicated to us by insurers or brokers. Then by the loss assessors or adjusters. Depending on the type and nature of the claim/loss, additional information may be collected from other sources such as police, firefighters, suppliers, vendors, witnesses, any other person or organisation that may assist in validating or handling the claim/loss, or other third parties involved in our business dealings with you.|
|b)||Purposes for using your data|
|Management of your claim/loss.|
Sending important information about your claim/loss and other administrative information.
Making decisions regarding the assessment, processing and settlement of your claim/loss.
To investigate the cause and cost of your claim, we may collect data relating to the circumstances, cause and cost of the claim/loss and any information that may be relevant for insurers to accept the claim.
|c)||Use of collected data|
|The collected data can be forwarded to your insurers and to third parties involved in the claims/losses/investigations, such as lawyers, adjusters, police and justice departments, etc.|
|d)||Usefulness of the processing of personal data|
|The usefulness of processing your personal data is to determine the extent of any liability in the event of a claim/loss and if necessary, to arrange repairs, replacements or payment.|
2. Data retention period
The data is stored and used for a period in accordance with the existing legislation.
3. Data hosting
All data collected and processed by SW Associates is hosted within the European Union.
However, in the event that one of the Principals (Insurers) of SW Associates is located outside the European Union, SW Associates, in its capacity as data processing manager, implements all necessary measures to ensure the security of our clients’ data.
If you wish to know the destination of your data (outside the European Union), we invite you to contact us by email at: firstname.lastname@example.org
4. Right of access and rectification of your data
In accordance with the European regulations in force, you can exercise this right by contacting us, at the following address:
SW Associates – 29 rue Taitbout, 75009 Paris
Or by email at: email@example.com
In accordance with Article 40 of the above-mentioned law, all applications must be accompanied by a photocopy of a valid signed ID card and mention the address at which SW Associates may contact the applicant. The reply will be sent within one month of receiving the request.
The right to portability concerns only the personal data and not the complete claim/loss file.
5. Use of « cookies »
A cookie is a small text file saved by the browser on your computer, tablet or phone that keeps track of your visit.
SW Associates implements all technical and organisational measures to ensure the security of the personal data processing as well as the confidentiality of personal data.
As such, SW Associates takes all the necessary precautions, in view of the nature of the data and the risks presented by processing it in order to preserve the security of the data and in particular, to prevent them from being deformed, damaged or that unauthorised third parties have access (physical protection of premises, authentication processes with personal and secured access via confidential identifiers and passwords, logging connections).